Environmental Law Alert – Firm Represents Advocates in Rulemaking Leading to Significant Reductions in Emissions from Oil and Gas Operations in Colorado – Update from Kaplan Kirsch

On February 20, 2026, the Colorado Air Quality Control Commission (Commission) adopted rules to continue to reduce emissions of methane and volatile organic compounds (VOCs) from oil and gas operations in the state. Kaplan Kirsch represented Colorado Communities for Climate Action (CC4CA) (a coalition of 47 local governments) and Environmental Defense Fund (EDF) (an international environmental organization) to successfully advocate for these nation-leading regulations. Colorado is the first state in the country to adopt such rules and the adoption continues Colorado’s leadership in reducing methane emissions from the oil and gas sector. Firm attorneys Thomas Bloomfield, Sarah Judkins, and Sarah Berman led these efforts for EDF, which involved drafting briefs, presenting live testimony and negotiating rule language that was adopted by the Commission. Rebecca Glenn and Sarah Keane represented CC4CA.
Among other provisions, EDF and CC4CA supported, and the Commission adopted, the Air Pollution Control Division’s proposed clarification that existing requirements for leak detection and repair (LDAR) apply to wellhead-only production facilities. The approach ensures that operators are implementing Regulation 7’s instrument-based LDAR requirements at wellhead-only production facilities, which is important as studies have demonstrated that such facilities can leak, releasing methane and impacting nearby residents. EDF also supported additional proposals to align with the EPA requirements, which the Commission adopted.
Kaplan Kirsch attorneys have extensive experience practicing before the Commission and representing clients on a range of air quality, climate, and compliance issues in Colorado and other states.
Please reach out to Thomas Bloomfield with any questions or for more information.